Selective Mutism as Barrier in Sulh Conference Settlement
Norman Zakiyy1*, Hasnizam Hashim1, Maizatul Farisah Mokhtar2, Dina Imam Supaat1
1 Faculty of Syariah and Law, Universiti Sains Islam Malaysia, Nilai, Negeri Sembilan, Malaysia
2 Tamhidi Centre, Universiti Sains Islam Malaysia, Nilai, Negeri Sembilan, Malaysia
*Corresponding Author: [email protected] Accepted: 15 November 2022 | Published: 1 Decenber 2022
DOI:https://doi.org/10.55057/ijarih.2022.4.4.4
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Abstract: The sulh conference provides opportunities for the parties to discuss openly with each other with the aid of the sulh officer as a facilitator to their discussions. However, current literature on sulh pays little attention to the issue of whether mutism especially selective mutism can lead to non-effective discussion among the parties and the sulh officer. Thus, the main objective of this preliminary study is to analyze the barriers faced by a party who suffers from selective mutism in a Sulh Conference. This study uses a qualitative method through content analysis of relevant library-based materials. The findings show that it is crucial for the sulh officer to identify the presence of the characteristics of selective mutism in a party prior to holding a sulh conference. The barriers faced by persons suffering from selective mutism must be addressed to ensure that the sulh settlement process is carried out justifiably, especially in line with the Sulh Work Manual, irrespective of whether the settlement of the dispute is successful or otherwise. It is suggested that the party suspected of suffering from selective mutism undergo diagnostic screening to determine whether he is suitable to participate in a sulh conference or otherwise.
Keywords: sulh, child custody, selective mutism
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1. Introduction
Sulh is a form of court-annexed Alternative Dispute Resolution (ADR) implemented in the Syariah courts in Malaysia. It provides an alternative to litigation in the settlement of disputes.
Online sulh offered since the Covid-19 pandemic is still being implemented and remains a good alternative that protects the safety and health of the parties by enabling the sulh officer to assist the parties to communicate actively via virtual meetings (Adnan, & Buang, 2021). Sulh involves a contractual relationship between two parties who agree to abide by certain terms as a settlement on a voluntary basis (Muhammad 2007; Azahari, 2005). Thus, a significant part of concluding a contract is the need for the parties to communicate with each other irrespective of whether the sulh conference is conducted physically or online.
Generally, cases that are suitable for settlement by way of sulh are a breach of promise to marry, muta’ah, jointly acquired properties (harta sepencarian), maintenance of wife, child custody (hadhanah), and maintenance of the child. The settlement of these cases via sulh mechanism depends largely on the ability and willingness of the parties to communicate efficiently with one another. Notably, communication is an integral part of dispute resolution irrespective of whether the mode of resolution is by way of litigation or Alternative Dispute
Resolution (ADR) procedures. Thus, non-communication is not a feature of any dispute resolution procedure.
The Sulh Conference is conducted according to JKSM Practice Direction No.3 of the year 2002, Sulh Work Manual of JKSM 2002, and the Sulh Officer Ethical Code of JKSM 2002. In accordance with the Sulh Work Manual of JKSM 2002, the sulh conference is chaired by a sulh officer as a third-party neutral. Thus, the sulh officer’s role and function are crucial to ensure that the sulh session is conducted effectively. The sulh sessions allow the sulh officer to approach the parties individually, or with both parties present, and a combination of both in a series. The sulh officer must also communicate with the parties and identify the barriers faced by the parties that might affect the efficacy of the sulh process.
2. Problem Statement
ADR procedures provide avenues for parties to communicate with each other for amicable settlement. As such, the active participation of the parties is essential to encourage possible settlement. Notably, a disabled person is defined as a person who has a problem with the function of the body or structure and has complications in accomplishing an undertaking or action; with a participation constraint (World Health Organization, 2021). A disabled person, especially one who is mute might face considerable barriers to communication. In this context, a mute person refers to one who is unable to communicate (Stöppler, 2021). While mutism is given sufficient emphasis in clinical attention, it has received relatively less attention in psychiatric studies (Aggarwal et. al, 2010). Having said that, selective mutism is under- researched and commonly misdiagnosed even though children might suffer from it (Camposano, 2011).
Selective mutism is a disorder where a person is not able to communicate in certain social circumstances. Recent literature on sulh does not provide guidance on how the sulh officer is to deal with a party that suffers from selective mutism. The sufferer of selective mutism might intend to communicate, but in certain situations find that they are not capable of doing so.
However, very little knowledge is known about selective mutism as a barrier to the ability of a person to communicate effectively during settlement discussions. Under such circumstances, this study is of great significance to the practice of sulh by improving the current procedure for managing a sulh session, involving parties with mutism in specific and parties with disabilities in general.
3. Research Objectives
The main objective of this research is to determine whether selective mutism is a barrier to sulh settlement. The sub-objectives are:
a. Examine the term “selective mutism”.
b. Examine the personalities of a person who suffers from selective mutism.
c. Analyse how the personalities of a person who suffers from selective mutism become a barrier to sulh settlement.
4. Research Questions
Several research questions are listed below to draw the objectives of the study. The questions are as below: -
a. What is known as “selective mutism”?
b. What are the personalities of a person who suffers from selective mutism?
c. How do the personalities of a person with selective mutism become a barrier to sulh settlement?
5. Research Methodology
This conceptual study uses a qualitative method through document analysis of relevant library- based materials. Document analysis in the study of Syariah and law involves a method of evaluating documents systematically from printed and electronic sources where data obtained will be analyzed and interpreted. In this study, data were obtained from primary and secondary sources. Primary data were obtained from al-Qur’an, relevant statutes, various Syariah Court Civil Procedure Rules, case reports, journal articles, and court practice directions. Secondary data referred to in this study include scholarly articles, journals, official websites, and other electronic materials on selective mutism and the practice of sulh.
6. Findings and Discussion
The findings from the literature analysis show that it is crucial for the sulh officer to identify the presence of the characteristics of selective mutism in a party prior to holding a sulh conference. The unresponsiveness of a party suffering from selective mutism order (such as keeping quiet) is a likely hindrance to the duty of the sulh officer to facilitate settlement for the parties.
The Meaning Attached to the Term “Selective Mutism”
Selective mutism is an anxiety disorder caused by a failure to communicate in a social environment and begins in early childhood (Krysanski, 2003; Hultquist, 1995; Omdall &
Galloway, 2007; Alexandra & Nilli, 2016). Basically, any party who attends the Sulh Conference is given the freedom to communicate as mentioned in the Sulh Work Manual.
However, in the case of selective mutism, a party does not communicate due to an inability or unwillingness to communicate. In this context, selective mutism must be distinguished from the types of physical abnormality such as delayed speech or aphasia (defect or loss of language capabilities).
The Common Personalities of a person who suffers from selective mutism
The term "mutism" refers specifically to a person who suffers from profound congenital deafness and is thus affected by reason in deaf-mutism (Stöppler, 2021; Aggarwal et al, 2010).
Deaf persons are known as persons with issues in communication, are introverts apart from unwilling to socialize (Vostanis, Hayes, Du Fu & Warren, 1997); and even face problems in interactions with their caretakers (Soltani, Eskandari, & Golestan, 2012). Deaf-mute persons are either deaf and dependent on the use of sign language to communicate or both deaf and not able to speak (Tin, Lin, Swe, & Mya, 2017; Leigh, & Andrews, 2016). By way of comparison, a person who suffers from selective mutism only communicates in certain situations (The British Psychological Society, 2015).
According to National Organisation of Rare Disorders (2011), selective mutism is described by the inability to speak in certain social conditions. Symptoms include extreme nervousness and public anxiety. Sufferers of selective mutism are shy but are not disabled from the ability to speak (Adelman, 2007). Sufferers carry certain characteristics such as being “compliant,
reticent, and almost “frozen” around strangers” (National Organization of Rare Disorders, 2011). A person with selective mutism may come from a family in which there is a history of anxiety disorders or shyness. A child with selective mutism if neglected may continue into adulthood with destructive effects (Johnson, & Wintgens, 2017), especially in relation to starting communication in a nonverbal manner such as pointing or writing (Shipon-Blum 2020).
Selective Mutism as Barrier to Sulh Settlement
The procedure of the sulh conference caters to the communication between a normal person and another normal person.
In accordance with Chapter 4 – Early Presentations by the Disputing Parties of the Sulh Work Manual, the following steps must be communicated effectively to the parties by the Sulh Officer:
1) The Sulh Officer shall ask the Plaintiff to make a presentation, the impacts that arise, and any suggestion on settlement.
2) The Sulh Officer shall then ask the Defendant to present what is disputed by him, the impacts that arise, and any suggestion for settlement.
3) After hearing the presentations from both parties, the Sulh Officer shall identify the scope of the dispute between the two parties.
4) The Sulh Officer shall conduct and manage the information obtained to determine: - a) Issues or problems that need to be resolved;
b) Positions of the parties in the dispute.
c) Their interests.
d) Alternative (optional) solutions.
Rules on the conduct of sulh generally allow the parties to communicate. For example, Rule 5 of the Syariah Court Civil Procedure (Sulh) (Federal Territories) Rules 2004 stipulates that the Chairman (namely the Sulh Officer) shall, where possible, assist the parties to resolve the dispute concerning the subject matter of sulh and shall give each party an opportunity to be heard. Similarly, Chapter 3 – Preliminary Statement (al-ta’arruf) of the Sulh Work Manual requires sulh officers to communicate to the parties about the procedures of conducting the sulh session. The sulh officer will encourage the parties to ask questions to ensure that they fully understand the whole process. Apart from that, the sulh officer needs to explain to the parties the difference between the sulh process and other types of settlement processes such as arbitration and trial.
The said chapter also states that the Sulh Officer shall clarify the procedural rules that must be obeyed, including:
a) All parties shall speak following their turn.
b) When a party speaks, the other party shall listen and pay attention.
c) When speaking, the speaker shall be calm and not raise his voice.
d) All parties shall speak and act in a polite manner and not harass the personality of the opponent.
e) All parties are not allowed to communicate directly between themselves except in the presence of the Sulh Officer.
Based on the above guidelines of the State of Selangor Syariah Judiciary Department (Jabatan Kehakiman Syariah Negeri Selangor) and the personalities of a person who suffers from
mutism, it can be gainsaid that a party who suffers selective mutism might not be able to communicate effectively throughout the sulh process. Non-communication or miscommunication might also take place when one of the parties suffers from selective mutism.
In addition, without effective communication and engagement during the sulh session, the sufferer of selective mutism may not be able to deliver his or her expectations clearly which are essential to develop positive feelings and assist in avoiding further conflicts.
Although subsection 10(3) of the Syariah Court Sulh Procedure (Negeri Sembilan) Rules 2016 allows the Sulh Officer to determine the issues, interests of the parties, and options of settlement, it is unlikely that he may get the parties to cooperate with him if one of the parties is having problem in communication. The Sulh Conference may also be terminated when one of the parties withdraws from the session, leaving the sulh officer with little choice but to terminate the session (see, for example, section 13 of the Syariah Court Sulh Procedure (Negeri Sembilan) Rules 2016 (N.S.P.U.2) on Termination of Majlis Sulh).
In furtherance to that, a party who suffers from selective mutism may find it difficult to conclude a valid contract due to its inability to communicate effectively during the presentation. The inability to present one’s case effectively might affect the essentials of sulh which must be in line with the rules applicable to a contract, especially the first rule where there must be an offer and acceptance between the parties. Furthermore, the Al-Majalla Al Ahkam Al Adaliyyah (The Ottoman Courts Manual (Hanafi)) has formulated 40 articles to deal with sulh from Articles 1531 to 1571. It defines sulh as a contract removing a dispute by consent pursuant to Article 1531. And it becomes a concluded contract by offer and acceptance.
As mentioned hereinbefore, sulh involves a contract between two disputants who agree to abide by certain terms as a settlement on a voluntary basis (Mohammad, 2007, Azahari, 2005).
Parties who are unable to communicate might not be able to conclude a valid contract that consists of an offer and acceptance and further consideration.
A person who suffers from selective mutism requires medical attention. Schrader (2016) has proposed the use of dramatherapy to overcome shyness, self-consciousness, and anxiety apart from mentioning other forms of therapy such as cognitive behavioral therapy (CBT), psychotherapy, hypnotherapy, or neuro-linguistic programming (NLP). These methods, however, are not within the capacity of a sulh officer because he is not skilled to handle such a situation. Simply putting on a smile and directing one's body language towards the said party who suffers from selective mutism is not sufficient to cajole him or her to communicate effectively for settlement.
Based on the above explanation, the inability of the party who suffers from selective mutism to communicate accordingly also affects the ability of the sulh officer to host the sulh conference effectively. The Sulh Officer is tasked to address the issue of a party who suffers from selective mutism and not a party with hard of hearing problems or deafness, where the latter requires the use of Gestuno, or International Sign Pidgin and International Gesture (IG) for communication purpose. Based on the procedures laid down in Chapter 4 of the Sulh Work Manual, early presentations by the parties are essential to enable the sulh officer to identify the crux of the disputes and work out a conflict map for possible settlement.
It is much more difficult for the sulh officer to encourage the party who suffers from selective mutism to communicate in an online sulh. It is known that common technical issues with virtual conferences include poor connection and sound quality, echo, and incompatibility of the
system. These technical issues are also barriers to the ability of the sulh officer to effectively host the Conference.
Suggestions to Assist Parties with Selective Mutism
Practically, parties to a sulh conference are assisted by the sulh officer to ensure the smooth running of the settlement discussion. The sulh sessions allow the sulh officer to approach the parties individually, or with both parties present, and a combination of both in a series. To achieve this, effective communication skills are essential in nurturing the positive outcome of the sulh conference. It is thus crucial for the sulh officer to improve his communication strategies to ensure that the parties pay attention and feel listened to. Notably, there are two verses of the Quran that support the function of a sulh officer to resolve disputes. The first verse is “if two groups amongst the believers join into a disagreement, you make a settlement amongst them” (Al-Qur’an. Al-Hujurat 49:9). The second verse is “if a spouse worries about viciousness or abandonment on her husband’s role, there is no fault on them if they organize an agreeable settlement amongst themselves” (Al-Quran. Al-Nisa 4: 128).
The sulh work process begins with the Registrar/Senior Assistant Registrar receiving a case file from the Assistant Registrar. According to Practice Direction JKSM 8/2003, the Registrar shall after fixing the date for the Sulh Conference, issues a Notice of Sulh to the parties.
However, a party may or may not attend the sulh conference due to certain unexplained reasons.
At this stage, the Registrar might not have the privilege to obtain information as to any lacking in terms of communication skills or any disability that is present in a party. The cause of selective mutism is not due to physical abnormality. Thus, it is not easy for the inexperienced sulh officer to detect whether one of the parties is suffering from selective mutism.
As shown in the literature, a party that suffers from selective mutism is commonly conforming, reticent, and not socially adaptable to different situations. On the Sulh Conference day, the sulh officer meets the parties in person. The sulh officer must learn to speak clearly whilst listening and observing the person's reactions. This provides an opportunity for him to identify any symptoms of selective mutism (nervousness, shyness, and difficulties in communicating).
The sulh officer may consider adjourning the conference to a suitable date to enable the party who is suspected of suffering from selective mutism to undergo diagnostic screening because the diagnosis of selective mutism can only be confirmed by way of medical evaluation. The result of the diagnostic screening can be used as a guide to decide whether sulh is a suitable dispute resolution procedure to resolve the parties' dispute. According to Makhtar (2011), sulh officers who receive appropriate training will affect the success or failure in handling the Sulh Conference. Thus, it is suggested that sulh officers be given the opportunity to attend short courses relating to effective ways to handle parties with mutism. In addition, the court may adopt ways to encourage a party who suffers from selective mutism to participate in a sulh conference. For example, the court may do the following: (a) Provide an appropriate room or setting which is convenient to the party who suffers from selective mutism to reduce stress, and (b) Provide the opportunity for the party who suffers from selective mutism to visit the sulh conference room to make him or her familiar and get convenient with its surroundings.
Apart from that, the Sulh Officer should encourage participation by doing the following: (a) Allow the exchange of information in verbal (speaking or sign language) and nonverbal (in written and gestures) ways; (b) Allow the use of speaking notes to assist them in their respective presentations; and (c) Allow the parties to reduce their presentations in written form which can
be shown to the parties during the sulh session. This reduces excessive shyness and anxiety in the party who suffers from selective mutism.
7. Conclusion
It can be surmised that effective communication ensures the parties gain the best benefit out of a settlement plan. The officer's task is to facilitate the parties in reaching a possible settlement.
In this connection, a sufferer of selective mutism must be treated differently compared to a non-sufferer. This is because the former is devoid of fair bargaining power to participate in a settlement discussion. In addition, the unresponsiveness of a party suffering from selective mutism order (such as keeping quiet) might be a barrier to the duty of the sulh officer to facilitate settlement for the parties. Thus, the challenges in using sulh to resolve a dispute where symptoms of selective mutism are present in one of the parties should not be taken lightly.
8. Suggestion for Further Studies
This preliminary study contributes to the scholarly literature on sulh. It addresses the importance of doing more in-depth studies on issues of communication and its relevance in the sulh process. It is imperative that further studies are conducted to find practical ways to accommodate parties who suffer from selective mutism or other forms of disorders so that they may be assisted throughout the sulh session.
Acknowledgment
The paper is prepared based on the ongoing research conducted under the Islamic Science University of Malaysia (USIM) short research grant entitled “The Challenges of Syariah Court Annexed Mediation in Negeri Sembilan”. Research Grant code:
PPPI/TAMHIDI/0019/051000/17919. Our research group gratefully acknowledges the funding received for this research grant from Universiti Sains Islam Malaysia (USIM) as well as the support and assistance given throughout this ongoing research.
References
Al-Quran. (All Quranic translations in this writing are based on Vickar Ahamed).1999.
Interpretation of the Meaning of The Glorious Qur’an. Kuala Lumpur: TR Group of Companies.
Adnan, W.A.W., & Buang, A.H. (2021). Pelaksanaan Sulh Dalam Kes Tuntutan Harta Sepencarian Melibatkan Hartanah di Mahkamah Syariah Malaysia: Satu Analisis.
Malaysian Journal of Syariah and Law, 137-152.
Al-Majalla Al Ahkam Al Adaliyyah (The Ottoman Courts Manual (Hanafi)).
http://legal.pipa.ps/files/server/ENG%20Ottoman%20Majalle%20(Civil%20Law).pdf Adelman, L. (2007). Don't Call me Shy. LangMarc Publishing; 1st edition (September 15,
2007)
Aggarwal, A. Sharma, D.D., Kumar, R. and Sharma, R.C. 2010, Mutism as the Presenting Symptom: Three Case Reports and Selective Review of Literature. Indian J Psychol Med. 2010 Jan-Jun; 32(1): 61–64.
Alexandra, H. and Nili, M. 2016. Current Opinion in Pediatrics, Volume 28, Number 1, February 2016, pp. 114-120(7), Wolters Kluwer,
American Speech-Language-Hearing Association (ASHA). https://www.asha.org/Practice- Portal/Clinical-Topics/Selective-Mutism/, accessed on 10 September 2021.
American Psychiatric Association website. https://www.psychiatry.org/patients-
families/ptsd/what-is-ptsd. (accessed on 31 July 2021).
American Psychiatric Association (2013). Diagnostic and Statistical Manual of Mental Disorders (Fifth ed.). Arlington, VA: American Psychiatric Publishing.
Azahari, R. Sulh dalam Perundangan Islam, Kertas Kerja Seminar Isu-isu Mahkamah Syariah VII, Universiti Islam Antarabangsa Malaysia, 29 January 2005.
Bowen, G. A. (2009). Document analysis as a qualitative research method. Qualitative Research Journal, 9(2), 27–40. https://doi.org/10.3316/QRJ0902027
Camposano, L. (2011). Silent Suffering: Children with Selective Mutism. The Professional Counselor.Volume 1, Issue 1. NBCC, Inc.
Gales,M. and Steve Young, S. (2008), "The Application of Hidden Markov Models in Speech Recognition", Foundations and Trends® in Signal Processing: Vol. 1: No. 3, pp 195-304.
Hultquist, A.M. (1995). Selective Mutism: Causes and Interventions. Journal of Emotional and Behavioral Disorders. https://doi.org/10.1177/106342669500300205
Hayden T.L. (1980). Classification of Elective Mutism Torey L. Hayden, © 1980 American Academy of Child Psychiatry.
https://www.torey-hayden.com/research/classification-of-elective-mutism.pdf Johnson, M. Alison Wintgens, A. The Selective Mutism Resource Manual: 2nd Edition
Routledge, 28 Jul 2017
Jabatan Kehakiman Syariah Negeri Selangor, Pamphlet berkaitan Majlis Sulh;
https://www.jakess.gov.my/hakam/sulh.pdf ) (akses 12 Julai 2021).
John, M. (1998). Helping Young Children Overcome Shyness. Educational Resources Information Centre (ERIC).
http://www.poleris.edu/~malouffj/shyness.htm (accessed 14 September 2021).
Krysanski, V.L. (2003). A Brief Review of Selective Mutism Literature, The Journal of Psychology, 137:1, 29-40, DOI: 10.1080/00223980309600597
Leigh, I.W. and J. F. Andrews, J.F. (2016). Deaf People and Society: Psychological, Sociological and Educational Perspectives, Psychology Press, 2016. 2nd Edition, https://doi.org/10.4324/9781315473819
Makhtar, M.A. (2020). Soft Skills of Mediator. Thesis – Master Science of Construction Contract Management, Faculty of Built Environment, Universiti Teknologi Malaysia.
MedicineNet, Medical Definition of Mutism, Medical Editor: Melissa Conrad Stöppler, MD Reviewed on 3/29/2021, https://www.medicinenet.com/mutism/definition.htm.
Muhammad, R.W. (2008). The Theory and Practice of Sulh (Mediation) in the Malaysian Shariah Courts. 16, IIUMLJ 33-35.
Muhammad, R.W. (2007) Sulh Sebagai Alternatif Penyelesaian Kes di Mahkamah Syariah dlm Kaedah Perundangan Dan Bidang Kuasa Dan Tatacara Mahkamah Syariah. Kuala Lumpur: Dewan Bahasa Dan Pustaka.
National Organization of Rare Disorders (NORD). Rare Disease Database.
https://rarediseases.org/rare-diseases/mutism-selective/
Omdal, H. and Galloway, D. (2007). Could Selective Mutism be Re-conceptualised as a Specific Phobia of Expressive Speech? An Exploratory Post-hoc Study.
https://doi.org/10.1111/j.1475-3588.2007.00454.x
Rittner, P.. When Your Parents Have Mental Illness: Healing Childhood Trauma. (21 February 2018). National Alliance on Mental Health. https://www.nami.org/Blogs/NAMI- Blog/February-2018/When-Your-Parents-Have-Mental-Illness-Healing-Chi (accessed 31 July 2021).
Schrader, C. (2016). Breaking through the walls of shyness (overcoming shyness, self- consciousness and social anxiety through dramatherapy). Routledge International Handbook of Dramatherapy, 2016
Sulh Work Manual for Syariah Court,
http://www.esyariah.gov.my/portal/page/portal/BI%20Sulh/Sulh%20Work%20Manual
%20for%20Syariah%20Court
Syed Sabiq. 1990. Fiqh al-Sunnah. Kaherah: Dar al-Diyan li al-Turath. v.3, p.389.
Shipon-Blum (2020). What is Selective Mutism? Selective Mutism – A Comprehensive Overview (August 2020).
https://selectivemutismcenter.org/whatisselectivemutism/
Soltani, F., F. Eskandari, and S. Golestan, “Developing a gesture-based game for deaf/mute people Using microsoft kinect,” in Proceedings of the 2012 6th International Conference on Complex, Intelligent, and Software Intensive Systems, CISIS 2012, pp. 491–495 The Research Digest, The British Psychological Society, The experiences of adults with
"selective mutism", in their own words
https://digest.bps.org.uk/2015/07/08/the-experiences-of-adults-with-selective-mutism- in-their-own-words/
Tin, W., Lin, Z. -. Swe, and Mya, N.K. (2018), “Deaf mute or Deaf,” Asian Journal of Medical and Biological Research, vol. 3, no. 1, pp. 10–19. https://doi.org/10.1155/2018/1013234 UN Convention on the Rights of Persons With Disabilities.
https://www.un.org/development/desa/disabilities/convention-on-the-rights-of-persons- with-disabilities/frequently-asked-questions-regarding-the-convention-on-the-rights-of- persons-with-disabilities.html#iq6
Vostanis, P., M. Hayes, M. Du Feu, and J. Warren, “Detection of behavioural and emotional problems in deaf children and adolescents: Comparison of two rating scales,” Child: Care, Health and Development, vol. 23, no. 3, pp. 233–246, 1997.View at: Publisher Site | Google Scholar https://doi.org/10.1111/j.1365-2214.1997.tb00966.x
World Health Organization (2021). Disabled People in the World in 2021: Facts and Figures.
https://www.inclusivecitymaker.com/disabled-people-in-the-world-in-2021-facts-and- figures/
Enactment
Syariah Court Civil Procedure (State of Negeri Sembilan) Enactment 2003 [N.S. P.U. 5/2004].
Reported Cases
Wan Abdul Aziz v Siti Aishah [1975] 1 JH 47.
Wan Abdul Aziz v Siti Aishah [1977] 1 JH 50.
Sidek Bin Ludan V Public Prosecutor (1995) 3 MLJ 178
Statutes
Practice Direction No. 3 of year 2002 (JKSM/100-24/5(14) (Jabatan Kehakiman Syariah Malaysia)
Syariah Court Civil Procedure (State of Negeri Sembilan) Enactment 2003 Syariah Court Sulh Procedure (Negeri Sembilan) Rules 2016
Syariah Court Civil Procedure (Sulh) (Selangor) Rules 2001
Syariah Court Civil Procedure (Sulh) (Federal Territories) Rules 2004 Syariah Court Civil Procedure (Sulh) (Malacca) Rules 2004
Syariah Court Civil Procedure (Sulh) (Johor) Rules 2004 Syariah Court Civil Procedure (Sulh) (Penang) Rules 2006
Syariah Court Civil Procedure (Sulh) Federal Territory Rules 2004, Syariah Court Civil Procedure (Sulh) Melaka Rules 2004
and Syariah Court Civil Procedure Enactment, Selangor 2003
The sulh session in a Sulh Conference, is conducted according to JKSM Practice Direction No.3 year 2002, Sulh Work Manual of JKSM 2002 and the Sulh Officer Ethical Code of
JKSM 2002.
Child Act 2001